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Hogsalt Privacy Policy & CCPA

Privacy Policy | CCPA
Privacy Policy

Last Updated: May 2022

WE RESPECT THE PRIVACY OF EVERY INDIVIDUAL WHO VISITS THIS SITE
Hogsalt’s Privacy Policy (“Policy”) explains how www.Hogsalt.com (the "Website") and any mobile applications that we may issue and collect and otherwise process personally identifiable information, including Job Posting Information as defined below (collectively, "Personal Information"). You may choose to submit Personal Information (such as your name, address, e-mail address and telephone number) to us on our Website. We collect, use and disclose personal Information for business purposes only unless otherwise contained. We will not share this information in from what is disclosed in this Policy. If you have any questions about this Policy, the website, please contact us at dataprotection@Hogsalt.com.

WHO IS COLLECTING YOUR INFORMATION
The Website is owned and operated by Hogsalt.com. ("Hogsalt, “we”, “us” or “our”). This policy applies only to our website and to our Hogsalt.com is the sole owner of the information collected on the website.

WHAT INFORMATION WE COLLECT
Personal Information from the Website is gathered in two ways: (1) indirectly, i.e., certain Website information about you, such as domain name, IP address, browser type and page views, mobile device ID and type, and geolocation which is collected through our website's to provide certain functionality to you, to remember you when you return, to customize our Website to your preferences and manage content, and compile statistics about Website usage; and (2) directly, when (a) you voluntarily submit Personal Information such as, first and last names, addresses, email address(es), phone numbers, birthdate, marital status, number of children and their ages, social network and data, preference information, or survey answers/opinions, in connection with various marketing and promotional activities, surveys or contests conducted on the Website; (b) when you register to become a user of the Website we will collect the password and security question/answer; and (c) when you submit resumes to the third party applicant tracking system described below and respond to job postings through the Website. When we collect this type of information, we will notify you as to why we are asking for information and how this information will be used either in this Policy or separately at the point at which the information is collected if not described in this Policy.

LINKS
The website contains links to other sites whose privacy policies may differ from those of Hogsalt which we recommend you carefully review and consider. We cannot be responsible for the privacy policies and practices of other websites even if you access them using links from our Website.

GEO LOCATION
If you have provided permission through your mobile device to allow us to collect location information through the Hogsalt may obtain your physical location information from technologies like GPS, Wi-Fi, or cell tower proximity. The App may use the geo-location features of the App (GPS or network-based) and geo-location information that is collected through the web to provide you information regarding Hogsalt restaurants, events and promotional offers in or near your area or current location. You are able to withdraw your permission for Hogsalt to acquire physical location information from your mobile device through your mobile device settings, although Hogsalt does not control this process. If you have questions about how to disable your mobile device's location services, we recommend you contact your mobile device service provider or the mobile device manufacturer.

RIGHT NOT TO PROVIDE INFORMATION
In certain jurisdictions, you may have the right not to provide Personal Information. However, if you elect not to provide such information, you may not be able to utilize certain services on the Website.

JOB POSTINGS
The Website may include job postings from time to time for various Hogsalt Restaurant locations or our corporate offices. In some cases, the Website might list the email address of a contact person at the applicable hiring company. If that hiring company is Hogsalt or a Hogsalt affiliate, any Job Posting Information sent to that email address will be maintained in accordance with this Policy. All such Job Posting Information may be used by the applicable hiring company for the purpose of assessing your suitability for current and future job vacancies and to pursue your recruiting process. HOGSALT MAKES NO REPRESENTATIONS AND WARRANTIES REGARDING THEIR INFORMATION SECURITY OR PRIVACY PRACTICES. PLEASE NOTE THAT HOGSALT DISCLAIMS ANY AND ALL RESPONSIBILITY OR LIABILITY RELATING TO USE OF YOUR JOB POSTING OR OTHER PERSONAL INFORMATION (INCLUDING RESUMES AND CVS) BY ANY INDEPENDENT OWNER, MANAGER OR OPERATOR OF A HOGSALT LOCATION.

If at any time you want your Personal Information, resume or CV to be deleted, you simply need to notify the hiring Hogsalt.

DATA RETENTION AND DISPOSAL
Hogsalt keeps customer information for as long as is necessary for business purposes, or as legally required by appropriate state, federal and regulatory bodies. Retention periods vary depending on the type of information and how it is used. The criteria we use to determine the appropriate retention periods include: • How long we have a relationship with you and provide services or products to you.
• Whether there is a legal, contractual or similar obligation that requires us to keep your information for a certain period of time.
• Whether you have consented to retention of your information for a longer period of time.
• Whether the personal information is sensitive.
When we no longer need to use or retain your personal information, records, both physical and electronic, are destroyed.

COOKIES/ONLINE TRACKING
Some information that we collect about you is collected passively through the use of "cookies." Cookies are small files of information, which save and retrieve information about your visit to the Website - for example, how you entered and navigated our Website, and what information was of interest to you. We use this information to remember you when you return and to customize our Website to your preferences.

There are two types of cookies: session and persistent cookies. Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site. Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. Disabling Cookies. In certain jurisdictions, you will be asked to provide consent for your cookies when accessing our website. The request does not always reappear when you revisit the site. You may click to revise your cookie settings.

Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Website to, among other things, track the activities of Website visitors, help us manage content, and compile statistics about Website usage. We and our third party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

THIRD PARTY ANALYTICS/TRACKING
We use automated devices and applications, such as Google Analytics, to evaluate usage of our Site. We also may use other analytic means to evaluate our services. We use these tools to help us improve our services, performance and user experiences. These entities may use cookies, tracking pixels and other tracking technologies to perform their services. We do not share your personal information with these third parties.

ACCESS, CORRECTION, AND CHOICE
You have choices about the collection, use, and sharing of your personal information, including:
• Deletion: You can request that we erase or delete all or some of your personal information (e.g., it is no longer necessary to provide services to you).
• Change or Correct: You can review and edit your personal information by logging onto the Site and visiting your account. Please note that personal profile information supplied by you at the Site can be accessed by you online at any time and at no charge.
• Object to or Restrict Use: You can request that we stop using some or all of your personal information or restrict our use of your personal information.
• Access and/or Take: You can request a copy of your personal information. o Right to Portability – provides the ability to request personal information in machine readable format (i.e. CSV).
• Marketing: Users who no longer wish to receive our newsletter or promotional materials may opt-out of receiving these communications by clicking the unsubscribe link at the bottom of the email.
• Withdrawing Consent: If we have collected or processed your personal information with your consent, you may withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information based on other lawful processing grounds.

If you request access, correction, amendment or deletion of your Personal Information and you have more than one account with us, you will need to instruct us on each account separately. Reasonable access to Personal Information will generally be provided within thirty (30) calendar days at no cost to you, subject to limited exceptions prescribed by law or excessive requests. For your protection, we may need to verify your identity before fulfilling your request. Please note that we may need to retain certain information for recordkeeping purposes or to complete transactions that occurred prior your request.

We will also retain your personal information if reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse. We may also need to retain your personal information if required by gaming industry regulations, federal tax statutes and other legal requirements (e.g., information on our customers who self- report; tax reporting documents; player winnings, and any statistics, reports or listings that are required to protect our casino properties). We aim to keep our information about you as accurate as possible. If you would like to access, update, review or change the details you have supplied us with, please contact us as set out below.

SUBSCRIBERS/ORDERS
In order to use and participate in certain programs or services offered by Hogsalt via the Website, you must first complete a registration form. In order to use or participate in such programs and services, we will need to collect certain Personal Information about you, such as your name, email address and contact details, and, if applicable, credit card payment information. This information is used to communicate with you about specific services, offers, benefits and features on our Website for which you have expressed interest or registered. For some Website or App services, you may be asked to provide a password and user identification. This information is collected to confirm eligibility for use of the online services and to establish the identity of the authorized user. You are responsible for maintaining the confidentiality of that password and user identification.

HOW WE SHARE YOUR INFORMATION AND WHO WE SHARE IT WITH
During the course of business, we may disclose, transfer or otherwise make available Personal Information to our affiliates and third-party service providers who have been legally contracted to provide services on our behalf, and are prohibited from using it for any other purpose. Job Posting Information is shared with independent operators and/or managers of the Hogsalt locations, and Hogsalt and its affiliates as discussed above.

Your Personal Information may be maintained and processed by our affiliates and other third party service providers in the US, Canada or other jurisdictions. Third- party vendors that may receive personal data include payment card processors and financial institutions for transactions and financial management; on-line Rock Shop and retail product vendors, prize fulfillment company, travel agency, on-line reservation service provider, on-line job applicant service provider, survey research firm, and website analytics firm. In addition, all local, state, federal and foreign countries as mandated by their reporting requirements; and governmental authorities to comply with legal, regulatory or administrative requirements, or to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required by Canadian, US or other law. We may also disclose your Personal Information where necessary for the establishment, exercise or defense of legal claims, to investigate or prevent actual or suspected loss or harm to persons or property, or as otherwise permitted by law.

We may transfer your Personal Information as an asset in connection with the sale or transfer of all or part of the business (including transfers made as part of insolvency or bankruptcy proceedings) or as part of a corporate reorganization or other change in corporate control.

CHOICE/OPT-IN
Our users are given the opportunity to 'opt-out’ to having their Personal Information used for purposes not directly related to the purposes for which it has been collected. For example, our online Rock Shop retail merchandise order form has an 'opt-out' mechanism so users who buy a product or register for a service from us, but don't want any marketing material, can keep their email address off of our lists. Some jurisdictions may require ‘opt-in’ only.

HOGSALT – 3RD PARTY DISCLOSURE POLICY
We may, under limited circumstances, send you offers for related products or services from affiliated Hogsalt companies or jointly offered by Hogsalt together with select third parties. These offers are sent only to those users who have indicated their acceptance to receiving marketing materials from Hogsalt.

CONSENT TO SHARING OF PERSONAL INFORMATION
As a global organization, data we collect may be transferred internationally throughout Hogsalt's worldwide organization and to Hogsalt’s headquarters in the United States. Some of the jurisdictions to which data is transferred may not provide the same level of privacy protection as your local jurisdiction. By using and purchasing services and submitting Personal Information through the Website, you consent to such transfers of your Personal Information. Without such consent, Hogsalt is not able to provide you with access to its online services and other programs made available on the Website.

EU/US PRIVACY SHIELD COMPLIANCE
Hogsalt complies with the EU/US Privacy Shield framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member and treaty countries, and the United Kingdom. We have certified that we adhere to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program and to view our certification page, please visit www.privacyshield.gov/. In compliance with the EU/US Privacy Shield Principles, Hogsalt commits to resolve complaints about your privacy and our collection or use of your personal information. European Union citizens with inquiries or complaints regarding this privacy policy should first contact dataprotection@Hogsalt.com Please include your name, address and phone number or e-mail in all communications and state clearly the nature of your request or concern. If you wish to make a request to access the personal information we collect and store about you.

If Hogsalt transfers your personal data to a third party, we will ensure the third party is contractually obligated to process your data only for limited, specific purposes consistent with this policy, to apply the same level of protection to that data as the EU-U.S. Privacy Shield Principles, and notify us if it makes a determination that it can no longer meet this obligation. Upon notice, Hogsalt will take reasonable and appropriate steps to stop and remediate unauthorized processing. In cases of onward transfer to third parties of data received pursuant to the EU-US Privacy Shield, Hogsalt is potentially liable.

PUBLIC FORUMS
The Website may make chat rooms, forums, message boards, and/or news groups available to its users. Please remember that any information you disclose in a public forum will be available to other visitors to our Website. To the extent you disclose your Personal Information in public forums, the use of the information by third-parties will not be subject to this Policy.

PROTECTING CHILDREN
Hogsalt is mindful of the privacy of children as children merit specific protection with regard to their personal data, as they may be less aware of the risks, consequences and safeguards concerned and their rights in relation to the processing of personal data. For these reasons, promotions activities by Hogsalt addressed to children always receive specific attention and protection Hogsalt always rely on consent as lawful basis for processing of children information, and we always get consent from whoever holds parental responsibility for the child.

HOW TO ACCESS AND UPDATE USER INFORMATION
Users who no longer wish to receive our newsletter or promotional materials may opt-out of receiving these communications by clicking the unsubscribe link at the bottom of the email or contacting customer care. We aim to keep our information about you as accurate as possible. If you would like to access, update, review or change the details you have supplied us at dataprotection@Hogsalt.com

HOW WE ENSURE THE SECURITY OF YOUR DATA
We have implemented technical, physical and administrative measures, as well as policies and procedures designed to safeguard your Personal Information from unauthorized access, use, disclosure, modification or destruction and will continue to update these measures as new technology becomes available. Although we take efforts to protect your Personal Information, we cannot guarantee the security of your Personal Job Posting Information collected by the independent owners and operators of the Hogsalt locations. Any transmission of Personal Information is at your own risk.

HOW TO CONTACT US
You may address all communications to Hogsalt. Attn: Data Protection or e-mail to dataprotection@hogsalt.com. Please include your name, address and phone number or e-mail in all communications and state clearly the nature of your request. If you wish to make a request to access the personal information we collect and store about you.

CHANGES TO OUR PRIVACY POLICY
This privacy policy is effective as of April, 2022. If we make any changes to our Policy, we will post the updated Policy to the Website, provided on an updated homepage link, and may post it to other places we deem appropriate. Users who have authorized e-mail communication will be notified via e-mail of any material changes to the Policy. We will use Personal Information in accordance with the Policy under which it was collected.


California Consumer Privacy Act (CCPA):

This statement supplements the Privacy Policy of Hogsalt(“Hogsalt,” “we,” “us,” or “our”) and contains the disclosures required under the California Consumer Privacy Act (“CCPA”). For individuals who are California residents, the CCPA requires certain disclosures about the categories of Personal Information we collect and how we use it, the categories of sources from whom we collect personal information, and the third parties with whom we share it.

Please note that for California residents, the term Personal Information means information that identifies, relates to, describes, is capable of being associated with or could reasonably be linked, directly or indirectly, with a particular consumer or household as defined in the CCPA. All other capitalized terms have the same meanings as given them in the Privacy Policy.

If you are a California resident who has provided Personal Information to Hogsalt, or a California resident that reasonably believes that Hogsalt collected or stores their Personal Information, you may exercise your rights under the CCPA and submit your via email to dataprotection@hogsalt.com.

We do not sell your Personal Information as that term is defined in the CCPA or under Nevada Law (Section Chapter 603A of the Nevada Revised Statutes). We may provide your Personal Information to service providers as described in the “How We Share Your Information and Who We Share It With” Section of the Privacy Policy that perform services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of Hogsalt. Such service provider are prohibited retaining, using, or disclosing the personal information for any purpose other than for the specific purpose of performing the services for us.

You have the following rights under the CCPA:
Right to know about Personal Information collected, disclosed or sold California residents have the right to request that we disclose what categories of Personal Information that we collect, use, disclose or sell about you. You may also request the specific pieces of Personal Information that we have collected about you.

Right to request deletion of your Personal Information You may also request that we delete any Personal Information that we have collected from you, provided that we may retain Personal Information as authorized under the CCPA, including, but not limited to, retaining Personal Information necessary to provide our Services, detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, debug to identify and repair errors that impair our Site and Services, to enable solely internal uses that are reasonably aligned with your expectations based on the your relationship with us, comply with a legal obligation or otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which your provided it.

In order to submit a request, we will need to verify your identity. If you have an account with us that is password-protected, we may verify your identity through our existing authentication practices for your account. We may request two or more data points of Personal Information and other proof of identification depending on the nature of the request and the Personal Information requested to verify your identity.

Please note that following your verified request, we will send you your Personal Information from the following email address:
dataprotection@hogsalt.com (Any response to your request, including any Personal Information may be sent as an encrypted file). We will process and respond to your request within 45 days (in some cases, as is allowed under the CCPA, this process may be extended by an additional 45-90 days). Please note that once you have submitted a request, we will send you a receipt, acknowledging your request, within 10 days. If, for some reason, you do not receive such a receipt within 10 days of your submitted request, please send us an email to dataprotection@hogsalt.com as an error may have occurred. Please note, that regarding requests under the heading “Right to know about Personal Information collected, disclosed or sold” above, you may only make two such requests in a 12-month period, and the information provided need only cover the 12-month period prior to your request.

As a California resident, you also have the right to designate an agent to exercise these rights on your behalf. We may require proof that you have designated the authorized agent to act on your behalf and to verify your identity directly with us. Please contact us at dataprotection@hogsalt.com for more information if you wish to submit a request through an authorized agent.

We hereby inform you that if you exercise any of your rights under the CCPA, we may not deny you goods or services for that reason, or subject you to different prices than those paid by other consumers, unless provided otherwise under the CCPA, Federal, or State law.

NOTICE OF INFORMATION WE COLLECT Pursuant to California Civil Section 1798.100(b), this serves as notice of the categories of Personal Information that we collect through the Site and Services and the commercial purposes for which we collected that information. All of the categories of Personal Information we collect about you (as detailed below) come from the following categories of sources:
• You, including through your use of our Site and Services
• Automatically collected from you
• Our affiliate companies as listed in the Privacy Policy, including Hogsalt
• Third parties